The parties
Controller: the merchant — the legal entity that signs up for a Mercentia account and determines the purposes and means of processing end-customer personal data.
Processor: Mercentia Ltd, registered in England & Wales. Mercentia processes personal data on behalf of the Controller in the course of providing the platform described in the Terms of Service.
Roles and scope
This DPA applies to processing of personal data:
- That the Controller submits to the platform (catalogue, content, settings)
- That end-customers submit through Controller-operated storefronts
- That Mercentia collects directly to operate the platform (account, billing, audit, security telemetry)
Controller acts as Controller; Mercentia acts as Processor. For Mercentia's own purposes (account administration, billing, security, fraud) Mercentia is the independent Controller.
Subject matter, nature, and duration
- Subject matter: provision of the Mercentia platform
- Nature: storage, transmission, organisation, retrieval, analysis, and deletion of personal data
- Duration: term of the underlying Terms of Service, plus 90 days for deletion / retention obligations
- Categories of data subjects: Controller's customers and prospects, Controller's staff, Controller's wholesale buyers
- Categories of data: identifiers (name, email, address, phone), order data, communication content, payment tokens (never PAN), IP / device telemetry
Processing instructions
Mercentia processes personal data only on documented instructions from the Controller — primarily the Terms of Service, the Controller's configuration of the dashboard, and the Controller's API calls. Anything outside that is unauthorised processing unless EU or UK law requires otherwise, in which case Mercentia informs the Controller before processing unless the law prohibits the notice.
Technical and organisational measures
Detailed on the Security page. Summary:
- Encryption in transit (TLS 1.2+) and at rest (AES-256)
- Row-level security tenant isolation in PostgreSQL
- Argon2id password hashing; per-IP rate limiting on auth
- Append-only audit log retained 7 years
- Production access logged + restricted; quarterly access reviews
- Synthetic checkout monitoring + on-call rotation
- Dependency CVE blocking in CI
- Annual SAQ A self-assessment
Sub-processors
Current list on the Privacy page. Controller grants general authorisation for Mercentia to engage sub-processors from that list. We give 30 days' written notice before adding a new sub-processor. If you object on reasonable data-protection grounds, you may terminate the affected service.
Data subject rights
Mercentia assists the Controller in responding to data-subject requests (access, correction, erasure, restriction, portability, objection) via the dashboard's privacy tools and the /api/v1/gdpr/* endpoints — export, erase, consent updates, summary. We respond to Controller's assistance requests within 7 calendar days at no additional charge.
International transfers
Mercentia is operated from the UK. Where personal data is transferred to sub-processors outside the UK / EU, the transfer relies on:
- UK International Data Transfer Agreement (IDTA)
- EU Standard Contractual Clauses (SCCs), Modules 2 + 3 as applicable
- EU-US Data Privacy Framework where the recipient is certified
Supplementary measures (encryption, pseudonymisation, transparency reports from the recipient) are applied as required by the Schrems II guidance.
Breach notification
Mercentia notifies the Controller without undue delay — and in any event within 72 hours — of becoming aware of a personal-data breach affecting the Controller's data. The notification includes nature of the breach, categories and approximate numbers of data subjects and records, likely consequences, and the measures taken or proposed.
Audit and inspection
Mercentia makes available all information necessary to demonstrate compliance with this DPA. Once per 12 months, on 30 days' written notice, the Controller (or its independent auditor under NDA) may audit Mercentia's processing during normal business hours, at the Controller's expense. Audits cannot disrupt platform operations or other Controllers' data.
SOC 2 reports (once available) and the PCI SAQ A self-attestation are accepted as sufficient evidence in lieu of an on-site audit where the scope matches.
Termination + return of data
On termination of the Terms of Service, the Controller has 30 days to export personal data via the dashboard or the API. After that period Mercentia deletes or anonymises personal data, except where retention is required by law (tax, anti-money-laundering, audit). Backups age out within 30 days.
Signing this DPA
Every paid Mercentia account is covered by this DPA — accepting the Terms of Service incorporates it by reference. For merchants who require a countersigned copy for procurement records, email [email protected] and we'll return a signed PDF within 5 business days.